End-to-end tax counsel
We help corporates and private clients to take tax decisions that hold up under scrutiny by the tax authorities. We structure transactions, manage audits, and resolve disputes — in administrative proceedings and in court.
Tax planning
We design tailored tax strategies for corporates and for private clients. We review financing arrangements, real-estate and securities transactions, and group structures with a view to lawful, defensible optimisation.
- strategies for corporates and private clients
- tax structuring of transactions and M&A
- individual tax rulings and advance opinions
Tax audit support
We prepare the company for scheduled and unscheduled tax audits, attend every stage of the process, and record any procedural irregularities on the part of the authorities. We build the evidentiary record for a future appeal while the audit is still in progress.
- pre-audit preparation
- full audit support
- documenting procedural irregularities
Administrative appeals
We draft and file administrative complaints and represent clients before the State Tax Service, the Ministry of Finance, and other authorities. In many cases the matter is resolved before it reaches court.
- appeals against tax notices
- objections to audit reports
- representation before the STS
Tax litigation
We challenge decisions of the tax authorities before the administrative courts at every instance, up to the Supreme Court. Our work covers VAT refunds, the blocking of tax invoices, corporate income tax assessments, and financial penalties.
- every instance, up to the Supreme Court
- VAT and blocked tax invoices
- reversal of assessments and penalties
Customs disputes
We represent taxpayers in disputes over customs valuation, tariff classification, country of origin, and the application of preferential regimes. We handle post-clearance audits and appeals against decisions of the customs authorities.
- customs valuation and classification
- preferential regimes and origin
- post-clearance audits and appeals
Private clients and non-residents
We advise on income reporting, the taxation of foreign assets, controlled foreign companies (CFC), and automatic exchange of information under the CRS. We represent private clients in disputes with the tax authorities.
- declarations and CFC
- foreign assets and CRS
- inheritance and real estate
Four steps to a measured outcome
Request and briefing
We agree on the objectives, the risks, and the constraints. We sign an NDA before reviewing any primary documents or the client’s prior tax record.
Diagnosis of tax position
We review primary documents, contracts, accounting records, tax notices, and audit reports. We map the areas of risk and assess prospects in figures, not promises.
Roadmap
We set out the plan of action: procedural deadlines, parallel appeal tracks, evidence to be gathered, and a budget. Each step is agreed with the client before work begins.
Execution and defence
We draft procedural filings, handle administrative and judicial appeals, and represent the client before the tax authorities, the customs service, and the courts at every instance.
Why sound structure costs less than a tax assessment
Most assessments, fines, and criminal proceedings have their origin not in the inspector’s office, but at the stage of signing the contract and structuring the transaction. This is how we prevent problems long before the authorities take notice.
Start
Deal
Audit
Dispute
What to do, if…
Four typical situations in which the cost of the right response in the first twenty-four hours is measured in tens of millions of hryvnias of tax exposure. Expand each scenario to see the order in which we act.
…you have received an information request or an audit order
- we verify the legal grounds and the inspectors’ authority;
- we brief management and staff, and restrict communications;
- we determine which documents must be produced and which need not be;
- we record procedural breaches for later appeal.
…a tax invoice has been blocked or VAT registration suspended
- we analyse the grounds for blocking and the risk criteria that were triggered;
- we prepare a set of explanations and primary documents to lift the block;
- in parallel, we file an administrative appeal and court proceedings;
- we restore the client’s VAT-payer status and lift the restrictions.
…you have received a tax assessment notice with additional charges and a penalty
- we assess the prospects of reversal, on both the law and the case-law;
- we suspend the deadline for payment by filing the complaint;
- we appeal the assessment administratively and in court;
- we run the case through every instance, up to the Supreme Court.
…criminal proceedings have been opened under Art. 212 of the Criminal Code
- we coordinate the tax and criminal-defence tracks within a single strategy;
- we attend interviews, searches, and document seizures;
- we challenge the alleged unlawful benefit — the central element of the offence;
- we secure either the closure of the proceedings or an acquittal at trial.
A conversation about your matter — directly with the partner leading the practice
Describe the situation and you will receive a clear assessment of prospects, a list of documents to work with, and an indicative budget — without empty promises.